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(page created 7 June 2009, last major update 25 June 2009)

Our documents submitted to the Inquiry

Our full "Proof of Evidence" (45 pages!!) or Our "Summary of Proof of Evidence" (5 pages)

Our "Witness statements" - Dave Loudon of Mersey Tunnels Users Association   Professor Shaoul and Dr Anne Stafford of Manchester Business School (full version) or Professor Shaoul and Dr Anne Stafford of Manchester Business School (summary version).

Our "Opening statement" delivered on the Inquiry's first day.

Our closing statement delivered on the last day

The Inquiry

What has happened at each day of the Inquiry

INQUIRY website from which you can access most of the documents that are being considered and get a lot of other information.

It was expected that the Inquiry would last at least six weeks, but some of the opposition evaporated and it was than expected to last four weeks - (half of that was the Council's evidence). But it then went back to lasting six "weeks", though there has been a lot of blank time.
This is the timetable page.

This is the general guidance for the conduct of these Inquiries - Planning Inspectorate - "Notes for the Guidance of Inspectors Holding Inquiries into orders and Special Road Schemes".
The general format for objector's "appearances" is that you have a chance to cross examine whichever Council witnesses you have nominated (and those who have made "rebuttals" to your proof). The cross examination of the Council witnesses is difficult for various reasons, not least of which is that the Council witnesses are nearly always not going to agree with the point that you are making.
Then you present your case (which is generally largely limited to reading out a short written statement that you have submitted in advance), and then you are cross examined by the other side's QC.
Before you know it they will have you saying that the Council plans have got to go ahead immediately, because the bridge is badly congested and the only way that they can solve this and Halton will enter Paradise is to toll both bridges and direct almost all (80%) of the traffic over the new bridge and down the Central Expressway. Particularly as no one in Halton has a car and those that do have one have the responsibility to subsidise everyone else.....

Our submissions to the Inquiry are on the Inquiry website but are also here -
Our "Summary of Proof of Evidence" (5 pages)
Our full "Proof of Evidence" (45 pages!!)
Our "Witness statements" - Dave Loudon of Mersey Tunnels Users Association   Professor Shaoul and Dr Anne Stafford of Manchester Business School   Professor Shaoul and Dr Anne Stafford of Manchester Business School (summary).

This was our "Opening statement" delivered on the Inquiry's first day.

We had to submit documents at earlier stages. The contents are very similar to the Proof of Evidence -
Objection submitted 18 July 2008
Statement of Case submitted 9 November 2008
Addendum submitted 15 March 2009

What has happened at each day of the Inquiry

This is our reports, for news stories go to the news page - Day One of the Inquiry   Day Two of the Inquiry   Day Three of the Inquiry   Day Four of the Inquiry   Day Five of the Inquiry   Day Six of the Inquiry   Day Seven of the Inquiry   Day Eight of the Inquiry.

Day 1 of the Inquiry - Tuesday 19th May 2009

1. The Inspector explained the way that the Inquiry would be run. One important point is that the timetable is flexible, and even if you have seen a copy of the timetable it is likely to change. The timetable is supposed to be on the Inquiry website, though it does not seem to be there yet.

2. The QC acting for the Council made a long Opening statement, there was then another long one from Lillian Burns for the Alliance (FOE / Round Table), then a shortish one from me for the NAAT - "Opening statement".

3. The Council then had one witness before lunch - David Parr (the Chief Exec), and three after lunch - Steve Nicholson (the Project Director), John Brooks (Planning consultant) and Richard Threlfall (Financial consultant). The Financial consultant was not due to be heard till tomorrow, so at this rate many of the witnesses may be appearing a day earlier than on the timetable.

4. The witness reads out the summary proof that you can see on the Inquiry website. Yawn..... Anyone is allowed to question the witnesses - but only "for clarification". The real questioning is supposed to be in a week or two when each objector has their turn to put their case. At the start of their case the objector "cross examines" the Council witnesses that they nominated in advance. Most of the objectors present (including The Alliance, Prof Andrew Basden, NAAT, Paul Cooke and Chris Lee) asked some questions for "clarification", for what it was worth.

5. There were about 70 people there in the morning and about 40 in the afternoon. The Council had nearly all their 19 witnesses present, and about 5 legal people and I would guess another 5 from the Gateway team. There are 3 Inspectors and a Programme Officer. There were about 10 objectors present, so you can deduce that by the lunchtime those who did not have to be there had decided they had had enough.

6. The Council said that they had four new supporters - Halton Housing Trust, Homes & Communities Agency, Halton Chamber of Commerce, and Stobarts - where the QC read out a letter from Andrew Tinkler. It is surprising that Halton Chamber of Commerce are a prominent backer as many of their members are opposed to tolls and the Chamber does not appear to have voted on it.
"Homes & Communities Agency" is a Government Quango.
Backing from Eddie Stobart is also a bit odd, as most hauliers are boycotting the M6 Toll, and the firm appear to have asked the Government to in effect exempt them from those tolls - BBC - "M6 Toll road marks fifth birthday".

Day 2 of the Inquiry - Wednesday 20th May 2009

1. Though the free bridge which is to be tolled carries over 80,000 vehicles a day, today at the "Public" Inquiry there was exactly one member of the public present!!

2. In the morning the Council had two witnesses Mike Jones (Engineering & Construction consultant) and Ian Hunt (Project Design consultant).

3. In the afternoon they had four Council witnesses - Paul Beswick (Landscape & Visual Amenity consultant), Alan Pauling (Transportation consultant), Graham Russell (Wider Economic Impact consultant) and Dr Clare Twigger-Ross (Social Impact consultant). The last 3 witnesses were brought forward from Thursday (Day 3)as they are going faster than they expected.

4. Most of this is boring as the witnesses read out from the "summaries" that were published weeks ago, and questions are only allowed "for clarification". There were a few interesting bits of clarification -
  • The "Wider Economic Impact" evidence said that there was support from businesses and residents. It was asked whether this was support for a new bridge or for a new bridge with tolls on that and the existing bridge. The answer was that people had been told about tolls on the new bridge but not the existing bridge.

  • The 5,000 jobs created by 3MG includes jobs that will be relocated from other areas such as Warrington.

  • The "Regeneration Area" or "RA" that all the increased jobs figures in the report are quoted for is not a coterminous area. It is all the areas over the region that are deemed by the consultants to be "RA" based on vague DfT guidance **. The map at page 46 "Wider Economic Impacts" proof reveals that most of this so called "area" is not in Halton. It is in Liverpool!
    And another large part of this "Regeneration area" is in the river. The explanation was that this is the way that boundaries are drawn!

    ** It was not part of the clarification answer but another document indicates that the basis the consultants have used is that regeneration areas are "transport zones which contain 50% or more LSOAs (Lower level Super Output areas) in the worst 20% for deprivation in the country."

  • The Social Impact report covers deprivation and the effect of tolls on people (as you might guess people can't wait for the opportunity to pay them) but its maps of deprivation are very different from those used in the Economic Impact report "Social Impact" Appendice to proof (see pages 13 to 18). These maps only show Halton, yet in various places in the Social Impact report it refers to the same nebulous "RA" as in the Economic Impact report.
    •  5. Yesterday the Council said that they had four new supporters -Halton Housing Trust, Homes & Communities Agency, Halton Chamber of Commerce, and in particular Stobarts. These letters should be available to the Inquiry, but in fact only three of the letters were, and two of the three make no mention of the fact that there are to be tolls. The only one that does is the letter from Halton Chamber of Commerce which does support tolls on both bridges - though the Chamber members may not agree with what the Chamber says.
    The letter from Stobarts is curiously not yet available.
    As well as the four letters mentioned by the Council, there are another eight recently deposited. Two of them do not mention tolls. Two support tolls, one from an individual, and one from the FSB. This is an amazing letter as the FSB campaign against tolls, and it demonstrates the amazing prowess of the Council in achieving this Damascene conversion. Four of the letters, that the Council did not mention, appear to oppose tolls. One from an individual, one from a small business, one from the Friends of Liverpool Airport and one from Halebank Business Steering Group.

    Day 3 of the Inquiry - Thursday 21st May 2009

    This was a very short day, with only one witness - Dr Adrian Williams (Aquatic Ecology consultant), as other witnesses were not available to be brought forward. There was what was described as a game of "ping-pong" as some of the objectors sought clarification of the evidence. Amazingly the Council evidence does not claim that the life of the fishes etc will be so much better due to tolls. An oversight?

    Day 4 of the Inquiry - Wednesday 27th May 2009

    No we didn't lose something! The Inquiry did not meet Friday to Tuesday.

    Today was originally scheduled for four Council witnesses, they got through six - Yvonne Brown (Air Quality consultant) , Mr Paul Freeborne (Noise Quality consultant), Mr Paul Norton (Hydrodynamics consultant), Dr Keith Hendry (Surface Water Quality consultant), Paul Oldfield (Avian Ecology consultant) and Dr Ray Gemmell (Terrestrial Ecology consultant).

    The experts on air pollution and noise said that they compared different scenarios - no new crossing, no toll, low toll, high toll. They had assumed that traffic would continue to grow in the no new crossing scenario. In essence they claimed that the higher the tolls the less noise and air pollution in Halton. During the "questions for clarification" it emerged that there would be an increase in air pollution in Warrington and that the increase in pollution there would increase as the toll increased (the similar effects of noise outside Halton have been ignored by the Council). One objector asked whether the differences between the low and high tolls had allowed for different rates for HGVs but the experts didn't appear to know what the rates were or even if different classes of vehicles would be tolled differently.
    Both experts said that identified negative impacts in areas alongside the Central Expressway and on Wigg Island were of "low negative significance". The noise expert said that only 22 houses would qualify for noise reduction measures i.e. double glazing etc. It was said that the remainder would be protected by parapets and noise barriers, but the inspector pointed out that the one metre high barriers proposed would not be effective for HGVs as their noise source would be above the barrier height.
    It was not part of the evidence, but the obvious reason that the Council can claim that there is less pollution and noise in Halton is that there will be less traffic with two bridges that there is now with one. But the reduced traffic is on the existing bridge, there will be considerably more traffic going through the centre of the residential area down the Central Expressway. Widnes will not escape because the toll collection will substantially add to pollution on that side of the river.

    Day 5 of the Inquiry - Thursday 28th May 2009

    They had the last two Council witnesses this morning - Mr Nigel Cossons (Environmental Contamination consultant) and Alan Scarisbrick (Land Acquisition consultant).
    In the afternoon there was only one witness - Paul Cooke, who was also the first objector to be heard. He questioned Ian Hunt, mainly about who was taking the risks for long term repairs of the bridges and Steve Nicholson - the first question was "Should there not be a vote?" The answer was "No toll, no bridge." Most of the questions to Steve Nicholson were about risks and setting and reviewing the toll levels. It was said that the concessionaire would be taking the toll risk. In answer to one question it was revealed that the Council had applied to the Government for £42 million to spend on maintaining the present bridge.

    Day 6 of the Inquiry - Friday 29th May 2009

    Another short day. At the start it was confirmed that there would be an evening session next Wednesday (3rd June) at Runcorn Town Hall, Heath Road. The Council are to "advertise" it.
    There were only two objectors / witnesses.

    The first was Chris Lee on behalf of Great Sankey Parish Council. He read out most of his Council's proof of evidence, which said that the Council "welcomes an improved crossing and believes it is essential to the economic prosperity of the region", but were concerned about the tolling. Firstly as traffic would divert and increase congestion in Warrington. Secondly that the tolls would be a "tax" which would have a "detrimental effect on the economic welfare of the parish and the North West in general". The proof also referred to the tolls as a "tax on health". The proof concludes by saying that the Parish Council "objects to the proposals as currently outlined".

    However it was said that the Parish Council was not in fact objecting "per se", it fully supported the new crossing and even accepted that there "has to be tolling" including on the existing free bridge. The Parish Council were concerned about what the limits would be on tolls, as under the Halton Council plans drivers could be paying the equivalent of £2,000 a year to get to work (based on the maximum car tolls of £5 for a return trip, inflation by the time that the bridge opened, and the fact that this toll was coming out of taxed income so should be grossed up). Chris Lee also wondered if Halton Council's rebuttal of the claim that large goods vehicles would deter to avoid the tolls was a joke (The rebuttal said - "that drivers of such vehicles do not pay travel costs (including tolls) themselves. Therefore, they are likely to use the Mersey Gateway crossing.")

    The other witness was Councillor Leslie Ford who was the Leader of Vale Royal Council and is now Deputy Leader of Cheshire West and Chester Council. It was emphasised that he was speaking in a personal capacity and not on behalf of Cheshire West and Chester Council.

    Councillor Ford read out some parts of an objection that Vale Royal Council had made it was said in 2006 (which it was later implied by the Council meant that it was not relevant). In summary he said that he / Vale Royal Council supported a new bridge and had "no problem" with what was in effect tolling of the new bridge, but they objected to the tolling of the existing bridge. He suggested that if they wanted drivers to use the new bridge then they should do that in some other way. He said that drivers should have an untolled choice and that tolls would damage the economy. He also said that if the bridge has to be tolled then he was concerned what the charging regime would be and what the concessions would be.

    There were no members of the public present, apart from some Halton Borough councillors who were incredulous when during a break it was said that initially there would be less traffic crossing the river with two bridges than there currently is with one. We wonder why they would doubt this fact?

    Day 7 of the Inquiry - Tuesday 2 June 2009

    There was as usual a very small audience but amongst them this morning was Councillor McDermott and Martin and Philip from the Warrington Road Residents Association. Otherwise the Inquiry might as well be being held on the moon, as there is almost no one there in any capacity who lives in Halton.
    The day started with the Inspector saying that it was the largest collection of papers for an Inquiry that he had seen in 25 years. It was then NAAT's turn to present our case. It did not exactly go according to plan!!

    We had submitted various additional background documents the day before that mainly related to the rebuttals that the Council had issued at the end of last week, the Inspector said that our documents would be ignored. The numbers of earlier documents that we submitted had been changed and we were even told off for that. We also had a lot of questions and there was not sufficient time to get through them all and we were told off at various times as we cross examined.

    We questioned the Council's witnesses for "Corporate" (David Parr), "Financial" (Richard Threlfall ), "Transportation" (Alan Pauling), "Social Impact" (Dr Clare Twigger-Ross ), "Wider Economic Impact" (Graham Russell), and "Project Sponsor" (Steve Nicholson).
    Amongst the points to emerge were that the new bridge is being constructed so that trams can run under the main deck, almost none of the "regeneration area" jobs are in Halton, and the Financial expert is not an accountant but a financer (though as there are virtually no figures which are not "confidential" this is not a problem!).
    The nearest we (or anyone) can get to interviewing any of the councillors was to interview the Chief Executive. One of our questions to him was why if Halton submitted a plan at the end of 2004 for tolling both bridges was it not formally agreed by the councillors till 2007. Another question was why were people who wanted a new bridge but opposed tolls counted as supporters.
    We had one witness - Dave Loudon of the Mersey Tunnels Users Association, and we read the NAAT summary proof and were then cross examined. We stressed that we were neither lobbying for nor against a new bridge. There were various ways of dealing with congestion and even if building another bridge was the best one, then that would have to be compared with other road priorities in the region. But if a new bridge is built, and that and the existing brdge are tolled, then it will not only be worse than the existing sitaution, it will be a disaster.

    Day 8 of the Inquiry - Wednesday 3 June 2009

    There were two objectors heard today - The first was Professor Andrew Basden who lives in Frodsham and who was supported by Klaus Armstrong-Braun, an environmental campaigner from Flintshire. The second was Sandra Spruce representing Sutton Parish Council, which is just outside the Halton Council boundary.

    Sandra cross examined Steve Nicholson and Alan Pauling (Transportation). She asked about discounted tolls for those outside Halton and was told that there were no definite discount proposals for anyone. Frequent user discounts were likely, but lower tolls for "locals" would have to be negotiated with the concessionaire during the procurement discussions. It was said that tolls would "open up choice". Sandra said that people would chose to cross at Warrington and Thelwell adding to traffic chaos. The question of lower tolls for those on low incomes or unemployed was also raised. Steve Nicholson said that the Council could not give any commitments about any discounts prior to negotiations. The questions to Alan Pauling were about the present and anticipated traffic problems in Sutton Weaver which was between "the Devil and the Deep Blue Sea".

    The Professor thinks that a new bridge should not be built and said that the Council had not explored alternatives. Whereas others might be concerned about paying tolls, one of the Professor's concerns was that the concessionaire might encourage more traffic by frequent user discounts. The Professor was very concerned about "global warming" as he believed that the new bridge would increase CO2 emissions, when the Government target was to substantially reduce them. He was also concerned about all the traffic that would be routed down the Central Expressway through the middle of the residential area. One of many other points that emerged was that the "delinking" of the existing bridge was not part of this Inquiry.

    The one and only evening session of the Inquiry

    This was held at Runcorn Town Hall on Wednesday 3 June starting at 7 PM and lasting nearly three hours.
    Apparently some of the experts supporting the Council had no idea where the Town Hall was and had had to be given details for their sat navs.
    The session was informal, that is you didn't have to arrange in advance to say that you wanted to speak, you just turned up. There were about ten officials etc, and eighty members of the public which meant that people had to stand. If more people had known there would have been a lot more there (standing outside!!), but the Council "advertising" of the session was too late.

    The meeting started with the Inspector asking supporters to speak. Six people said that they were supporters including Councillor McDermott (Council Leader) another Labour councillor, plus one Tory and one Lib Dem. A Tory Parliamentary Candidate from Warrington was one of the six supporters though it was a bit confusing as he said that he opposed the tolls. Everyone else was very stongly against one aspect or other of the Council plans. These are some of the many points that were raised -
    "We live here, the barristers hired by the Council will just move on. Objectors can not afford barristers."
    "Plans are already causing housing blight, our houses have been devalued and we can't sell them. These effects are all in Runcorn, not Widnes."
    "Better to leave it as it is."
    "Why should we have to pay tolls to visit our families?"
    "They are hitting the finances and health of one of the worst off boroughs in the whole country."     There were LOTS of concerns about air quality, noise, traffic and accidents, and worries about construction traffic and rat runs.
    There were various suggestions that traffic should be routed down the Daresbury Expressway rather than the Central Expressway.
    On a show of hands as to who had got one of the 60,000 consultation leaflets that the Council said had been delivered to every household, there was not one hand raised.

    The other "Gateway" Inquiry.

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